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Respondent determined a deficiency of $2,522 in petitioners’
1994 Federal income tax. The sole issue for decision is whether
certain payments received by Harold Redman (petitioner) are in
the nature of workers’ compensation payments which are excludable
from petitioners’ gross income under section 104(a)(1).
Some of the facts have been stipulated and are so found.
The exhibits received into evidence are incorporated herein by
reference. At the time the petition in this case was filed,
petitioners resided in Medina, Ohio.
Background
In 1994, petitioner was employed as a firefighter by the
City of Cleveland. He is a member of Cleveland Firefighters
Local 93 (Union). Petitioner was injured on November 1, 1994,
while fighting a house-fire. As a result of petitioner’s
injuries, he was placed on “On Duty” injury status (ODIS) for a
total of 22 days. While on ODIS petitioner was paid $10,264.1
The payments were made pursuant to a provision in the Collective
Bargaining Agreement (CBA), which was agreed upon by the Union
and the City of Cleveland and approved by the City on April 1,
1992, in Ordinance No. 641-93.
Petitioner deducted $10,264 from his income on his Form
1040, U.S. Individual Income Tax Return. The amount petitioner
deducted was the identical amount which appeared on a letter
1This amount is rounded to the nearest dollar.
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